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or disclosure of Personally -Identifiable Information was or may have been involved, such <br />individuals may additionally be reported to the appropriate enforcement agencies. <br />X. Scanner Policy <br />A. Overview <br />The Privacy Rules require that Virtru implement appropriate administrative, technical, <br />and physical safeguards to protect the privacy of Personally -Identifiable Information. <br />B. Purpose <br />To provide instructions to all Virtru employees regarding the use of scanners with <br />respect to Personally -Identifiable Information and the measures necessary to maintain an <br />adequate level of security for such information. This policy defines rules necessary to <br />achieve this level of protection. These standards are designed to minimize the potential <br />exposure to Virtru from damages, which may result from unauthorized disclosure of <br />Personally -Identifiable Information. <br />C. Applicability <br />This policy applies to all Virtru employees, which is defined for the purposes of this <br />document to be employees of all current and future subsidiaries of Virtru. <br />D. Special Definitions <br />Scanner. An electronic copy of a document stored as a series of zeroes and ones (binary <br />data) that can be transmitted like normal computer data. When received by a computer, <br />the incoming stream is translated into dots creating a representation of the original <br />document. <br />Inappropriate Disclosure: The intentional or unintentional revealing of <br />Personally -Identifiable Information to people who do not have a need to know such <br />information. <br />E. Corporate Policies <br />Employees must exercise utmost caution when scanning and transmitting these <br />documents to their devices and parties outside of Virtru. Scans containing <br />Personally -Identifiable Information should only be received on and sent to user or <br />departmental specific computer in an encrypted format, or sent using Virtru's encrypted <br />email application. <br />F. Procedure <br />In the case where scanned data that contains Personally -Identifiable Information is <br />disclosed to an inappropriate party, the following procedure shall be followed: <br />1. The receiving party shall be contacted by telephone at the earliest opportunity and <br />requested to destroy the scan without reading. <br />23 <br />Rev.2015.8.25 <br />